5 Common Stormwater Management Problems
By Cory Sander
Your stormwater management program is just one of many things on your to-do list. With that in mind, it’s no wonder many EHS managers run into a few stormwater management problems now and again. To help you avoid these pitfalls, we’ve outlined the most common issues and given you a few tips for avoiding them.
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You didn’t hold stormwater training for some or all of your staff.
Most NPDES (national pollutant discharge elimination system) permits require some kind of training for employees. You don’t have to train every employee at your facility, but you do need to conduct training for any employee who works in an area where industrial materials or activities are exposed to stormwater. Or for employees who are responsible for activities related to permit requirements.
Typically, you’ll need to conduct training annually and make sure to hold make-up training for any employees who couldn’t make your first session. Training needs to covers both stormwater pollution prevention and response (in the event of prevention failure).
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You’re missing some of your required stormwater inspections.
As an EHS manager, there are a million things on your plate, so it’s easy for things to slip through the cracks now and again. Stormwater inspections are almost always a permit requirement and, typically, you’ll need to conduct them quarterly. Unfortunately, many companies miss one or two of these inspections each year, and the results could be costly.
Maybe you did the first and second quarter inspections but missed the third. The answer? You need a better system for keeping tracking of required inspections and logging the results. EHS software might be the answer for managing compliance.
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You did all your inspections, but they didn’t cover everything they should have.
Not all inspections are created equal. Is yours thorough? Does it cover all the materials and activities that could affect stormwater? It’s common to miss one or two items. Maybe that dumpster outside that’s usually—but not always—covered with a tarp. Fueling areas are another common thing that might be missed in an inspection. It’s key to look for rusting, leaking or evidence of past spills. To make sure you’re conducting comprehensive inspections, download our free stormwater inspection checklist.
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You forgot to renew your stormwater permit.
This seems obvious, but it’s easy to do. Typically, you only have to renew your general stormwater permit every five years, but if you don’t have a good system for tracking all your permits, you might forget. Try tracking all your permits, inspections and renewals in one place—whether that’s a spreadsheet or compliance management software. And be sure you have clear roles and responsibilities, so you know who’s responsible for managing each permit.
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You never update your stormwater pollution prevention plan.
It’s not a one and done document. Your stormwater pollution prevention plan is a written—and living—document that outlines your team and what activity each person needs to oversee. It should also include response measures and clearly identify a response team in case of an emergency.
Try updating it at least annually (if not more often). You’ll need to account for staff changes, as well as any changes at your facility. Is there a new activity or potential pollution source that might affect your plan?
Do any of these stormwater pollution problems sound familiar? Or are you on top of it all?